posted at 2:25 pm on December 14, 2011 by Ed Morrissey

Hot on the heels of catastrophically bad test results for LightSquared, their new strategy to get FCC approval for their commercial rollout has emerged — in St. Paul, Minnesota, of all places. Last week, lobbyists started a full-court press on state legislators in an effort to pressure US Senators Amy Klobuchar and Al Franken into pushing for the FCC approval that the 75% failure rate in NTIA testing should disqualify. While the lobbying efforts of the Lehman Group are not new — Minnesota State News announced their efforts back in September — the lobbying has taken a more urgent tone of late.

The e-mail, as MnSN wrote back in September, leans heavily on LightSquared as a popular project among rural voters, as well as a long list of current supporters. However, it makes a few curious claims as well in light of more recent developments, and it’s worth highlighting a couple of them. (The complete e-mail is at the end of the post.)

LightSquared has a contract with Best Buy, which plans to roll out a national branded Best Buy cell phone product using LightSquared’s network. This is an exciting new business opportunity for this important Minnesota Company.

An important note for consumers is that the very low wholesale rates that LightSquared will be charging its retail partners means retail cell phone rates for LightSquared’s partners are expected to drop by 33-50%! That is very good news at a time when business and household budgets are stretched.

Best Buy is indeed a big Minnesota-based company, and a LightSquared deal makes sense — especially if those claims on retail cell phone rates are true. They almost certainly are — thanks to the waiver LightSquared got from the FCC to proceed with its plans, based on using a part of the spectrum it already owns and which is most emphatically not authorized for cell phone service. Other cell phone companies had to buy cell-phone service spectrum at auction from the FCC and paid billions of dollars to do so. If the FCC makes the waiver permanent, LightSquared can undercut prices on existing cell-phone providers — which is what LightSquared and its parent Harbinger intended all along. It’s also why Sen. Charles Grassley and others are looking at the political connections between Harbinger and the Obama administration and the curious actions of the FCC to keep this project on course for a rollout.

The lobbyist letter mentions the issues of LightSquared’s interference with GPS devices — by blaming the long-existing GPS equipment:

The GPS industry has raised concerns about LightSquared’s signals causing interference for GPS devices. The inteference is caused because GPS devices have been mismanufacturerd to receive signals outside their FCC-authorized spectrum. This means that when LightSquared broadcasts signals within its FCC-authorized spectrum, GPS devices “squatting” in the LightSquared spectrum pick up LightSquared’s signals.

First, this is absurd. GPS devices are receivers, not transmitters, and receivers do not “squat” on spectrum. They are built to receive very weak signals from satellites in space, which means they have to have a great deal of sensitivity. This is the very reason why LightSquared’s spectrum was not authorized for cell phone service in the first place. Second, the GPS industry has sold millions of these receivers for more years than LightSquared has attempted to get itself cell-phone spectrum on the cheap from a politically-allied administration. They are not “mismanufactured” just because LightSquared now wants to establish terrestrial networks that will swamp out the satellite signals these devices need to receive in order to operate.

The letter continues:

Despite the fact that the GPS community has done nothing to mitigate a problem that is caused by its devices operating in LightSquared’s spectrum, the good news is that a fix is coming thanks to a significant financial investment by LightSquared. In addition, several GPS manufacturers have come forward and are working with LightSquared on a fix that will restrict GPS devices to receiving signals only within their FCC-authorized spectrum.

Once again, the FCC authorizes spectrum to broadcasters, not receivers, but even so, this claim of a “fix” prompts another question. Who has to pay for the “fix,” and will it work with all existing GPS devices already in the field? Minnesota legislators who ask this question are told that the “fix” costs only 50 cents a unit, and that it will only take a “minor programming tweak.” According to my source on Capitol Hill, that’s not so; it will take the addition of an antenna and other modifications to the unit to successfully pinpoint terrestrial location with a less-sensitive receiver.

On the question of who pays for fixing all of the existing GPS units, which would apparently entail sticking an antenna on millions of the newer-generation smartphones that provide GPS tracking, the lobbyist response is that because the devices are “mismanufactured,” their makers should issue recalls and retrofit at their expense. They claim that the government would make Detroit automakers whose gas tanks explode in collisions fix the problem themselves. Of course, these GPS devices are not exploding, and they operate perfectly well under the spectrum assignments the FCC has had in place for all the years before LightSquared wanted a waiver for the use of its satellite-communication frequencies, so it’s unlikely that the NTSB or Consumer Product Safety Commission will order a recall.

What does that mean? It means that an FCC approval of LightSquared will force millions of people to abandon their current devices and buy the less-reliable and less-convenient devices that would have to take their place. Harbinger won’t be paying for those retrofits, and neither will GPS manufacturers who would stand to make more money by forcing people to change out the devices at their own expense. And even if the devices are retrofitted, how convenient would a smartphone with a big antenna be?

But what about the massive NTIA testing failure? They have an explanation for that too — that the NTIA tested their system at much higher power levels than what will take place in the rollout of the LightSquared service. Anticipating this argument, the satellite-communications industry blog TMF Associates explains the NTIA’s approach on power:

As I mentioned on Friday, the test results from the draft NTIA report indicated that 75% of cellular and general navigation devices suffer from harmful interference. These are the 400 million “cell phones and auto systems” whichLightSquared claimed were “already compatible” with its network, based on the “new plan, which was announced in June”. Now LightSquared claims that the tests did not take into account “a critical element in LightSquared’s mitigation proposal to manage the power from its network that GPS devices will be able to receive”. However, this “power on the ground” proposal was first set out in a presentation to the FCC in early September, and was never part of LightSquared’s June proposal. That was only a day or two before the NTIA mandated this further round of tests, so it is hardly surprising that it was not considered as part of the recent testing.

It is important to note that this phase of testing related to operation solely in the lower 10MHz block of L-band spectrum at LightSquared’s revised operational power limit of 32dBW (exactly as proposed by LightSquared in June). I understand that the test criteria was a limit of 1dB increase in the signal to noise ratio (rather than the 6dB that LightSquared originally proposed but the NTIA refused to accept), with line of sight to the tower. LightSquared’s newer “power on the ground” limits proposed in September do reduce the output power below 32dBW (to as little as 21dBW, i.e. ~15 times less) on the shortest towers (because these will produce the highest interference level close to the tower). However, LightSquared also proposes to increase these power levels by 3dB (i.e. double) in Jan 2015 and another 3dB (double again) in Jan 2017, so that far more towers will be operating at the 32dBW output level tested by the NTIA. Even a tall tower operating at the full power level could have a vehicle passing nearby in line of sight to the main beam, e.g. if the tower is next to an elevated roadway.

All in all, it is certainly true to say that the government conclusions are based on conservative assessments of interference (modest impact on devices in line of sight to a tower operating at the maximum power level). However, this is understandable when general navigation devices are relied on for vehicle safety, including in light aircraft.

Don’t forget that the FCC required LightSquared to pass this NTIA test as a condition of commercial rollout. The NTIA concluded that “No additional testing is required to confirm harmful interference exists,” which means the FCC has to withdraw the waiver. Hence, we now see LightSquared’s lobbyists scrambling here in Minnesota to generate the kind of political pressure that could convince the FCC to change its mind, and if that’s happening in Minnesota, I’m willing to bet it’s happening in other states as well.

Here’s the e-mail that state legislators are receiving:

I’m writing to give you an update on a technology issue and to ask for your help.

I’m working on a rural technology issue that promises to provide universal 4G wireless broadband Internet and cell coverage to all rural residents by using a satellite instead of cell towers to transmit signals. LightSquared is a private company seeking approval from the FCC to turn on its nationwide cell phone and wireless broadband Internet system that is based upon a patented satellite technology.*This technology will allow 4G signals anywhere in the U.S., even in areas without cell phone towers. This promises tremendous new economic development opportunities for rural communities as well as assist First Responders and law enforcement personnel.

LightSquared has contracts with about 20 national and regional cell carriers so far, including Sprint and other carriers that serve Minnesota.

LightSquared has a contract with Best Buy, which plans to roll out a national branded Best Buy cell phone product using LightSquared’s network. This is an exciting new business opportunity for this important Minnesota Company.

An important note for consumers is that the very low wholesale rates that LightSquared will be charging its retail partners means retail cell phone rates for LightSquared’s partners are expected to drop by 33-50%! That is very good news at a time when business and household budgets are stretched.

The FCC concluded its public comment period on LightSquared’s application in August and is now reviewing that proposal. It is expected that a decision will be issued later this Fall.

Support for Expanded Wireless Broadband Internet and Cell Coverage Grows

There is continuing and growing support for providing reliable wireless broadband and cell coverage to rural Minnesota and lower cell rates to urban residents. This support is bipartisan and reflects leaders from rural, suburban and urban Minnesota communities. Individual leaders and organizations from across Minnesota voicing their support by sending letters to the FCC and leaders in Minnesota’s congressional delegation include:

But this is not a partisan issue or a rural/metro issue. DFL legislators also support expanded telecommunciations services in rural Minnesota and more affordable cell coverage in the Metro. DFL legilsators contacting Washington on this issue include:

*Minority Leader Senator Tom Bakk;

*Assitant Minority Leader Senator Terri Bonoff;

*Senator LeRoy Stumpf;

*Senator Rod Skoe;

*Senator David Tomassoni;

*Senator Keith Langseth;

*Senator Tony Lourey;

*Senator Gary Kubly;

*Senator Dan Sparks;

*Senator Kathy Sheran;

*Senator Ron Latz;

*Senator Mary Jo McGuire;

*Senator Linda Higgins; and

*Senator Larry Pogemiller.

DFL State Representatives contacting Washington on this issue include:

*Minority Leader Representative Paul Thissen;

*Assistant Minority Leader Debra Hilstrom;

*Represenative Kent Eken;

*Representative Paul Marquart;

*Representative Tom Anzelc;

*Representative Tom Rukavina;

*Representative Carly Melin;

*Representative David Dill;

*Representative Tom Huntley;

*Representative John Ward;

*Representative Larry Hosch;

*Representative Andrew Falk;

*Representative Lyle Koenen;

*Representative Terry Morrow;

*Representative Patti Fritz;

*Representative Jeanne Poppe;

*Representative Steve Simon;

*Representative Sandra Peterson;

*Representative Jim Davnie;

*Representative Bobby Joe Champion;

*Representative Jeff Hayden;

*Representative Erin Murphy;

*Representative Rena Moran; and

*Representative Tim Mahoney.

County Commissioners and County Boards from Counties including:

·* Dodge;

·* Douglas;

·* Hennepin;

·* Grant;

·* Kanabec;

·* Koochiching;

·* McLeod;

·* Pope;

·* Renville; and.

·* Swift.

Organizations:

·* Economic Development Association of Minnesota;

·* Minnesota Association of Townships;

·* Minnesota Ambulance Association;

·* Minnesota Farmers Union;

·* Minnesota High Tech Association;

·* Minnesota Work Force Council Association; and

·* North Memorial Health Care (one of only three Level 1 Trauma centers in Minnesota)

GPS Interference Issue Being Resolved

The GPS industry has raised concerns about LightSquared’s signals causing interference for GPS devices. The inteference is caused because GPS devices have been mismanufacturerd to receive signals outside their FCC-authorized spectrum. This means that when LightSquared broadcasts signals within its FCC-authorized spectrum, GPS devices “squatting” in the LightSquared spectrum pick up LightSquared’s signals.

Despite the fact that the GPS community has done nothing to mitigate a problem that is caused by its devices operating in LightSquared’s spectrum, the good news is that a fix is coming thanks to a significant financial investment by LightSquared. In addition, several GPS manufacturers have come forward and are working with LightSquared on a fix that will restrict GPS devices to receiving signals only within their FCC-authorized spectrum. Initial tests by three different companies have been positive and a conclusive solution is expected later this Fall. One GPS manufacturer, JAVAD (http://www.amerisurv.com/content/view/9228/), is already marketing a LightSquared-compatible device.

Ag Groups Reverse Opposition to LightSquared

The response to this imminent GPS fix has been positive. A number of leading national ag groups, including the Farm Bureau, the Farmer’s Union, the Wheat Growers, the Sugar Alliance and the Potato Growers, have reversed their earlier opposition to LightSquared and are asking the Congress to push the FCC to move forward with a solution to this problem that protects GPS AND allows LightSquared to proceed. A copy of their letter is attached.

How You Can Help

If you believe that rural Minnesota needs more tech jobs and consumers throughout Minnesota should have expanded cell phone and wireless broadband Internet options at lower prices, it would be helpful if you let Congressman Cravaack and Senators Klobuchar and Franken know and you urge them to contact the FCC. A sample letter for your consideration is attached.

Please note that the “ask” in the letter is very simple and is based upon the postiion taken by the Farm Bureau, Farmers Union, Wheat Growers, Sugar Alliance and others – ask the FCC to reach a settlement that allows rural residents to enjoy the benefits of BOTH vital GPS services as well as expanded broadband wireless Internet and expanded call coverage.

This letter positions you in a “win-win” position:

·*You support farmers and the agricultural industry by making it clear that you oppose a solution that results in disruption to GPS signals vital to farmers.

·*At the same time, you are also an advocate for rural economic development and job creation. You support the local Chambers of Commerce, economic development directors, county commissioners and others who seek enhanced opportunities for technology jobs in rural communities. You recognize the technology deficits rural Minnesota faces in seeking to attract economic development. You also support the First Responders and law enforcement personnel who need reliable and consistent cell phone coverage to communicate with hospitals, families, law enforcement personnel and others in times of crisis.

This “win-win” position is what former Senator Norm Coleman called for in an op-ed published this week in ROLL CALL, a Capitol Hill publication. A copy of this piece is attached, fyi.

Thank you for your help on this. Please let me know if you have any questions. Also, can you please send me a copy of the final letters you send?

Blowback

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Comments

Holy Shiznatch, that could be the longest thread ever to appear on HotGas.

Whatever it said, if there was something in there about enriching the demorat coffers and making sure Frankenstein and Klobuffoon rake in a few campaign dollars, then rest assured my two senators will support the measure.

“Eminent domain” via technology? Airports, highways, business parks, now cell phones? What else is for sale via political corruption? Used to be a joke, but are we close to taxing air? Seems light is now going to be taxed.

Franken isn’t nice. He’s a foaming at the mouth leftist loon. IIRC he tried to start a fist fight with a Conservative or two. Even tho an ad was run of him ranting and raving it was close enough that the dems were able to fraud their way to victory. BTW, his numbers went up and his opponent’s numbers went down after the ad.
Not all the people from MN are idiots, but many seem to be.

TL;DR: LightSquared bought a spectrum never intended for cell phone service, fails the standard testing for cell phone rollout, and then blames everyone else for the fact that their spectrum, never intended for cell use in the first place, doesn’t work!

Well now…you are all just racists. Its pretty obvious that you dont want the minorities to succeed. What? That comment dosen’t have anything to do with the topic at hand? Only a racist would point something out like that…In all seriousness tho, I live up here in Minnescrotum, and we seem to have a good batch of state reps for now. I guess only time will tell, tho. Sigh…still embarrased about 1984, tho. And Franken. And Klobuchar. And our resident Muslim.

Radio Frequency Interference was the reason why the FCC was established in the first place. If the FCC permits any commercial operation to interfere with any other operation, the FCC has failed to do it’s job, and the people working in and for the FCC need to be replaced.

This antiquated celestial technology of LightSquared will render current technology and its hardware useless. Yeah, if one thinks Verizon, AT&T, Sprint, T-Mobile etc.., will merely watch this decrepit newbie in the club and take a market share? Aint gonna happen LightSquared so you might as well accept the loss. Your technology is contaminated and at the very least as bad as the DOD has discerned. One can feel the panic of LightSquared.

they’ll bribe and muscle this through… launch these “cheap” phones that don’t work!, destroy the GPS systems all over the world then go bankrupt because NOBODY will want to buy phones that work any WORSE!

This is the most intelligent and thorough post on this topic I have read to date. Most things I have read on this get key points wrong, but you are correct in all respects.

Thank you, Ed.

The short version for those keeping score at home.

Basically, the FCC sold bandwidth that wouldn’t work for the purposes the buyer wanted to use it. The company either knew this or found it out later and decided to double down by using its political influence to either falsify the testing, or blame others for the fact their product will interfere with other products (some of it critical to the military and emergency services) which have been on the market for decades. Said company is still trying to use political pressure to avoid paying for its own costly mistake. If Lightsquared gets FCC approval, the customer will pay through the nose to have their devices that use GPS such as cell phones, retrofitted.

I’m sure they do, but the key word in that question is “Obama”: Obama is one of the founding investors in LightSquared, and both the FCC and the FAA work for him, so no matter how much they talk to each other, it won’t change the FCC’s final verdict.

And in the very real and very possible event that the alleged private venture Lightsquared satellite comes up dead in space for some reason, how many years will it take to get their system back up and running? Re-engineering, building, and launching a replacement satellite into space would take years and cost many hundreds of millions of dollars as opposed to sending a truck crew out and paying them a little overtime to have a problem fixed in a matter of hours, or maybe days in a worst case scenario. What then?

All of their excuses and efforts to ram this through via government overlook oversight despite the enormous pitfalls and blatant short-comings of the proposed Lightsquared system shows a lot of extremely unusual desperation. I’m guessing that some very powerful people investing in this boondoggle are the reason for their acts of desperation.

WOW !!
Seems to me that a whole lot 99%ers would suffer financially as they would need to replace/refit gadgets at their own cost while the 1% Wall Street folks get a lot of $’s. This cannot be from the Obama admin. Can it ?
I am sure that Apple might a thing or two to say about their iphone being “mis-manufactured” That is a new one for me.
There is NO rational need for Lightsquared product.

My guess is this move would be supported because, as mentioned, it would force all of us to buy new GPS devices and/or cell phones in order to retain use of the feature. Talk about a huge boom for the GPS and cell phone industry.

My guess is this move would be supported because, as mentioned, it would force all of us to buy new GPS devices and/or cell phones in order to retain use of the feature. Talk about a huge boom for the GPS and cell phone industry.

Crony capitalism at its finest!

Flashwing on December 14, 2011 at 3:46 PM

Just wait until the OWS crowd learns of it. If they can learn, that is.

Meanwhile, OWS is wasting time and energy trying to shut down west coast ports. If they really wanted to go after the “corrupt 1%” they would start with Obambi and his crony capitalists. But OWS won’t. If they did, they would be admitting that capitalism works, and the corrupt government influence on capitalism is what is causing all the problems.

OWS’ premise is that capitalism is a failure, so they stick to the low hanging fruit for their protests, like “Wall Street” and ignore the real source of our economic malaise.

The GPS industry has raised concerns about LightSquared’s signals causing interference for GPS devices. The inteference is caused because GPS devices have been mismanufacturerd to receive signals outside their FCC-authorized spectrum. This means that when LightSquared broadcasts signals within its FCC-authorized spectrum, GPS devices “squatting” in the LightSquared spectrum pick up LightSquared’s signals.

First, this is absurd. GPS devices are receivers, not transmitters, and receivers do not “squat” on spectrum.

I disagree with you, Ed. It’s not an absurd phrasing.

The receivers are susceptible to interference by signals at frequencies which are not designated for GPS operations. This is most certainly a type of squatting since it is now apparent that these devices have delayed the company that has legal licensed those frequencies to transmit on those frequencies.

I still don’t have certain definitive answers that I want about this issue, but I’m worried that Hot Air is on the wrong side of this issue.

What a bunch of crap. Consumer electronics are frequently required NOT to be hardened and to ACCEPT harmful interference as required by Federal law. That warning is printed directly on many devices.

strictnein on December 14, 2011 at 3:13 PM

This isn’t an issue of the devices being hardened. This seems to be an issue of the devices being deliberately designed to process signals being transmitted on frequencies that have been licensed to LightSquared.

This isn’t an issue of the devices being hardened. This seems to be an issue of the devices being deliberately designed to process signals being transmitted on frequencies that have been licensed to LightSquared.

blink on December 14, 2011 at 4:58 PM

No they don’t. LightSquared can still legally broadcast its satellite communications operations on those frequencies, for which the spectrum has been designated by the FCC. LightSquared wants to broadcast terrestrial network operations on those frequencies instead, for which that spectrum has never been approved. Hence the waiver.

What the heck does this mean. Since when would the spectrum have been intended for use of any technology that wasn’t previously invented before?

What was any spectrum intended for back in 1800? At what point was the spectrum intended for any use?

If something new is invented next year, then should the invented company be restricted from licensing any spectrum because the spectrum wasn’t “intended” for an application which didn’t exist until it was invented? And should the company simply be SOL because some other type of device is improperly allowed to be affected by the newly licensed spectrum?

What the heck does this mean. Since when would the spectrum have been intended for use of any technology that wasn’t previously invented before?

What was any spectrum intended for back in 1800? At what point was the spectrum intended for any use?

If something new is invented next year, then should the invented company be restricted from licensing any spectrum because the spectrum wasn’t “intended” for an application which didn’t exist until it was invented? And should the company simply be SOL because some other type of device is improperly allowed to be affected by the newly licensed spectrum?

blink on December 14, 2011 at 5:04 PM

You apparently have no clue at all as to how the FCC works, how spectrum allocation works, how licensing works, or broadcasting works. The entire reason the FCC exists is to prevent broadcasters from interfering with each other, which is why different frequency slices are allocated to specific types of broadcast usage.

You apparently have no clue at all as to how the FCC works, how spectrum allocation works, how licensing works, or broadcasting works. The entire reason the FCC exists is to prevent broadcasters from interfering with each other, which is why different frequency slices are allocated to specific types of broadcast usage.

Ed Morrissey on December 14, 2011 at 5:08 PM

If you have evidence that GPS systems are NOT susceptible to LightSquare transmissions on the frequencies licensed to them in the exact manner that it was licensed to them, then I’d LOVE to see it.

If you have evidence that GPS systems are NOT susceptible to LightSquare transmissions on the frequencies licensed to them in the exact manner that it was licensed to them, then I’d LOVE to see it.

blink on December 14, 2011 at 5:15 PM

The evidence is that they’ve been operating on those frequencies for years already — in the manner in which they’ve been licensed to do so. There is NO ISSUE with interference now, because the satellite signals are not strong enough to interfere with GPS systems. LS wants to use those frequencies to build a terrestrial cell-phone network, a use for which this spectrum is NOT LICENSED — which is why they want a waiver, and why the testing failure should mean that they don’t get one. A license for one purpose does not mean that a broadcaster can then do whatever the hell they want to do with it later, a point that you appear to be too obtuse to understand.

The evidence is that they’ve been operating on those frequencies for years already — in the manner in which they’ve been licensed to do so. There is NO ISSUE with interference now, because the satellite signals are not strong enough to interfere with GPS systems. LS wants to use those frequencies to build a terrestrial cell-phone network, a use for which this spectrum is NOT LICENSED — which is why they want a waiver, and why the testing failure should mean that they don’t get one. A license for one purpose does not mean that a broadcaster can then do whatever the hell they want to do with it later, a point that you appear to be too obtuse to understand.

Seriously, try reading the posts and the links before commenting.

Ed Morrissey on December 14, 2011 at 5:21 PM

When you start your post by stating…

Hot on the heels of catastrophically bad test results for LightSquared, their new strategy to get FCC approval for their commercial rollout

…one certainly isn’t led to believe that LightSquared has been commercially operating anything since you’re claiming that it is only now on the heels of a rollout.

But, if what you say here is true, then I apologize for raising my concern about this. Additionally, I would thank you for taking the time to address the concerns raised by an individual commenter. Additionally, I will apologize to causing an unnecessary distraction.

However, please keep in mind that my problems didn’t stem from my inability to read properly. And they most certainly didn’t stem from my lack of understanding with respect to any communication system – quite the opposite actually. Most of the news about this has come from sources which obviously don’t understand the primary issues making it more difficult to understand than it needs to be.

This isn’t an issue of the devices being hardened. This seems to be an issue of the devices being deliberately designed to process signals being transmitted on frequencies that have been licensed to LightSquared.

blink on December 14, 2011 at 4:58 PM

No they don’t. LightSquared can still legally broadcast its satellite communications operations on those frequencies, for which the spectrum has been designated by the FCC.

Ed Morrissey on December 14, 2011 at 5:03 PM

I have to add, however that my above comment still might be quite correct.

Just because LightSquared hasn’t already paid to use the spectrum in the manner in which is wants to use it doesn’t mean that the interference is necessarily being caused by a lack of GPS device “hardening”. From what I’ve read (including what was written by a credible commenter a few days ago), the fault does seem to be with the fact that GPS devices have been purposely designed with excessively broad receivers.

Again, this might not be the case, but I haven’t seen enough evidence to determine the truth with respect to this.

Again, this might not be the case, but I haven’t seen enough evidence to determine the truth with respect to this.

blink on December 14, 2011 at 5:35 PM

The issue isn’t being paid. It’s that the FCC allocated the spectrum on the basis that GPS transmissions would be adjacent to it, which is why they only allowed for satellite transmissions for those frequencies — so they wouldn’t get interfered with. If LS wants to continue being a satellite communications service, they can do so without any further action from the FCC. Years after those allocation decisions were made, they want to install a terrestrial network that will broadcast on those frequencies at a much, much higher power level that will then interfere with the GPS systems that have been in place for a very long time, including for military and aviation use.

Once again, that’s why they needed a waiver to use the frequencies for a purpose that the FCC did not allow, and why they have to show they won’t interfere with the very legitimate service that has been established next to it, and why the GPS industry does not have to “prove” that they won’t interfere with LS.

So, no. You’re very wrong, and once again it’s because you don’t understand the purpose and role of the FCC, spectrum allocation, and broadcast regulations.

GPS started as a military system. It became dual use with a nonmilitay function. The military function is still the most important. Even if light Squared was not interfering with the civilian system, which it does, it should not be allowed.

So, no. You’re very wrong, and once again it’s because you don’t understand the purpose and role of the FCC, spectrum allocation, and broadcast regulations.

Ed Morrissey on December 14, 2011 at 5:52 PM

Your comment has nothing to do with what I said.

Nothing you said supports the notion that the actual cause of the interference is due to the fact that GPS receivers are not hardened.

Nothing you said refutes the notion that the actual cause of the interference is due to the fact that GPS receivers are deliberately sensitive to frequencies outside of the spectrum allocated to GPS.

Again, I’ve yet to see definitive confirmation of this either way.

If the width of LightSquared’s signals (measured at a traditional 3 dB decrease in power or any other convention) is truly extending into GPS allocated bandwidth, then the fault of the interference falls on LightSquared. But if LightSquared’s signals measure very modest power (considered acceptable by normal FCC standards) within GPS allocated spectrum then the fault falls on the design of the GPS devices.

Again, I haven’t seen enough evidence to make this determination.

All this being said, I’m not claiming that any of this means that FCC is obligated to allow LightSquared to utilize the bandwidth in a manner which they haven’t already licensed. This is specifically referring to the hardening issue. Feel free to keep saying that I don’t know what I’m talking about in this regard – but I do.

The issue isn’t being paid. It’s that the FCC allocated the spectrum on the basis that GPS transmissions would be adjacent to it, which is why they only allowed for satellite transmissions for those frequencies — so they wouldn’t get interfered with. ….

So, no. You’re very wrong, and once again it’s because you don’t understand the purpose and role of the FCC, spectrum allocation, and broadcast regulations.

Ed Morrissey on December 14, 2011 at 5:52 PM

Just to add to what Ed stated. GPS is a spread-spectrum, broadband signal. Thus the low power of the transmitted signal. The adjacent bands were allocated by the FCC for satellite transmissions in order to minimize the possibility for interference with the GPS system and receivers.

Because GPS signals are broadband, their receivers and antennas are likewise broadband antennas. It is not economically nor physically (as in the laws of physics) feasible to build antennas and receiver systems with immediate drop-offs right at the GPS band, hence, there is a rolloff in the adjacent frequencies, making these receivers subject to receiving signals in those adjacent frequency bands. Even if the receiver systems are reasonably well designed, a reasonable rolloff can be subject to significant interference when the adjacent bands have signals that are significantly (by many dB as the lightsquared system would be) stronger than the GPS signal.

No, those units weren’t “mismanufactured”, they were appropriately designed and built in accordance with the GPS reception requirement and the adjacent band allocations as defined by the FCC and international agreement.

Feel free to keep saying that I don’t know what I’m talking about in this regard – but I do.

blink on December 14, 2011 at 6:25 PM

No. No, you really don’t. GPS receivers do not have to be “hardened” because they operate exactly as intended by the FCC, and furthermore, they don’t broadcast at all. That’s the reason the FCC doesn’t allow terrestrial networks to broadcast adjacent to those frequencies. If LS wants to do so, they have to show that THEY do not interfere with the millions of existing GPS devices that are working exactly as intended in the current spectrum allocation plan. In order to get an exception, LS has to show that their service will not disrupt others, not that an existing complying service has to adjust for their new product.

The burden is on LS to qualify for the waiver by demonstrating non-interference with existing, complying uses — or else buy frequencies in the parts of the spectrum allocated for cell phone service. They don’t want to do that because it will cost them billions of dollars.

Again, this is why the FCC exists — so that rogue broadcasters don’t just stomp all over existing systems, especially in regard to critical low-power satellite communications like GPS systems. If you don’t know that, then you really don’t have a clue about this issue, and it shows.

It is not economically nor physically (as in the laws of physics) feasible to build antennas and receiver systems with immediate drop-offs right at the GPS band hence, there is a rolloff in the adjacent frequencies

AZfederalist on December 14, 2011 at 6:39 PM

I will challenge this statement. A receiver band-pass filter with steep roll-off rates is possible AND inexpensive. Hundreds of inexpensive receivers utilize all types of steep roll-off rate band-pass filters.

Again, I still haven’t seen evidence that the GPS receivers in question are designed with adequately steep roll-off rate band-pass filters (which again – are not cost prohibitive) to operate in an environment in which the neighboring bandwidth is being used for any type of system.

Again, I’m not saying that this isn’t the case. I’m merely saying that I haven’t seen sufficient evidence to indicate that this is the case.

And again, ’m not claiming that any of this means that FCC is obligated to allow LightSquared to utilize the bandwidth in a manner which they haven’t already licensed. This is specifically referring to the hardening issue.

I’ve remarked in many forums of late that as one of the designers of the GPS satellites I had to learn a great deal about the GPS signals. As the designer for the pre-launch test receiver for the entire GPS signal train I also learned a lot of ways to interfere with GPS.

The signal itself is constrained to about 20 MHz by filters. Alas, almost every receiver out there in the wilds has no filtering, perhaps on the mistaken impression that this would improve accuracy. It does improve “cheapness,” of course. Without the filters GPS receivers that find a signal like LightSquared’s anywhere in their rather wide input bandwidth and antenna pattern will not work. The signal level at the receivers is very low compared to signals generated a few miles away. The satellite is a 10 watt “giant”, give or take some, at 12600 miles altitude. An equivalent level signal can be generated from a 1 milliwatt transmitter at 1.2 miles. The GPS signal has some anti-jamming properties. But the Light Squared signals are not one milliwatt. So receivers will suffer over wide regions. (I’m not being too specific here. I am also slightly fudging the analysis. At one time much of the data was classified and I’ve never received a proper debriefing on that data. It crimps my style; but, I respect my promises made at the time.)

{^_^}

herself on December 11, 2011 at 6:25 AM

I’m not saying that she’s not wrong. I’m just saying that I haven’t seen the evidence which shows that she’s wrong.

Take a look at the back of a GPS receiver, or cell phone, for that matter. There you will find an FCC ID number. Wonder why it’s there? It’s because they were built in compliance with FCC specs for GPS reception (and cell phone service). Those specs were published to manufacturers so that they could rationally build the receivers in compliance with the FCC’s intended use of the spectrum, with the understanding that adjacent frequencies would be used for low-power satellite transmissions.

Now, LS wants to use adjacent frequencies for high-powered terrestrial communications. That will interfere with the receivers built under FCC recognition of their compliance — and there are millions of them. Furthermore, as the NTIA testing showed, LS interferes substantially with 75% of them. That isn’t the fault of millions of compliant devices — it’s the fault of the higher-powered terrestrial broadcasts.

Your arguments about “hardening” are ridiculous. The FCC approved the specs of these receivers with the spectrum allocation plan in mind, precisely because these receivers have to be especially sensitive to pick up the low-power signals.

That’s the issue, and it has nothing to do with “hardening.” It has to do with millions of compliant, FCC-approved devices becoming useless because LS thought it could get cell-phone bandwidth on the cheap.

I haven’t read anything to suggest that FCC has determined the specific cause of this interference.

blink on December 14, 2011 at 7:16 PM

I should clarify this.

Obviously, the interference is being caused by the LS transmission. I meant to say that I haven’t read anything to suggest that FCC has determined whether the LS transmission is overly broad or if the GPS receivers are overly broad.

I agree that the problem might be that the LS transmission is overly broad, but I’d like to read some definitive confirmation of this.

But again, I’m not claiming that LS should be allowed to use their spectrum in a manner that isn’t licensed to them – even if the fault lies with the receivers.

Is it at all possible that use of Light Squared might be related to the “lost drone” in Iran? Where is the GOP in trying to get an investigation going? Obama cronies involved again?? Can someone please impeach this guy! How many acts of treason does BHO need to commit in order to be brought up on charges??

It’s because they were built in compliance with FCC specs for GPS reception (and cell phone service).

Ed Morrissey on December 14, 2011 at 7:30 PM

The FCC “specs” might or might not require sharp-cut off filters for these devices and the requirements for using the sticker might or might not be being met. I’ll look for a copy of FCC’s rule on this.

Apparently, Lightsquared has addressed this EXACT issue in this letter to FCC in October.

I’m not saying that Lightsquared is right any more than I’m saying that you’re wrong. I simply remain unconvinced by the existence of a sticker.

Your arguments about “hardening” are ridiculous.

It wasn’t my argument. I was responding to another commenter about it. I was telling him that the issue is unrelated to “hardening” as typically defined.

I will challenge this statement. A receiver band-pass filter with steep roll-off rates is possible AND inexpensive. Hundreds of inexpensive receivers utilize all types of steep roll-off rate band-pass filters.

…

blink on December 14, 2011 at 7:08 PM

Depends upon your definition of “steep” and also “inexpensive”. You also need to realize that even with a reasonable roll-off, the reception requirements for GPS receivers makes them very sensitive receivers (it’s been a number of years, so I don’t recall the received signal strength precisely, save that it is down in the noise), thus even with a reasonable rolloff at the band edges, a signal that is 10′s of dB’s above the signal strength of the GPS signal will easily saturate the receiver. What would be needed if lightsquared were allowed to change the allocation of the band would be unreasonable roll-offs at the band edges, hence the fact that their “solution” is a very large antenna (i.e, a large aperture required for sharp band definition) as well as very sharp rolloffs for the band edges of the receiver response.

There’s nothing sophisticated about a steep cut-off filter in the 1,000 MHz to 1,500 MHz range. I’ll check some catalogs to see about actual prices and roll-off rates.

thus even with a reasonable rolloff at the band edges, a signal that is 10′s of dB’s above the signal strength of the GPS signal will easily saturate the receiver.

This doesn’t make any sense. The receiver can be built such that no signal (zero power) outside the GPS spectrum is allowed to pass. GPS receivers are constantly bombarded by other signals that are 10′s of dB’s higher than GPS signals yet aren’t affected.

What would be needed if lightsquared were allowed to change the allocation of the band would be unreasonable roll-offs at the band edges,

I’m not sure if it would be unreasonable or not. I haven’t seen enough evidence to make this determination.

their “solution” is a very large antenna (i.e, a large aperture required for sharp band definition) as well as very sharp rolloffs for the band edges of the receiver response.

This is interesting evidence.

As you know, GPS systems previously required much larger antennae. This suggests that the tiny antennae’d GPS systems don’t receive a strong enough signal from a small antenna in order to have adequate filters. This suggests that GPS receivers became more and more susceptible to outside spectrum signals as the antennae got smaller.

It’s because they were built in compliance with FCC specs for GPS reception (and cell phone service).

Ed Morrissey on December 14, 2011 at 7:30 PM

More on this. It appears that the sticker claims compliance with Part 15 of FCC rules. According to Section 15.19, FCC seems to require that the sticker state:

This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.

It seems as if the “specs” aren’t very specific. It seems as if the specs merely require that: 1) the device, as an unintentional radiator, not interfere with other devices; and 2) the device must be capable of accepting interference.

Now, this raises an interesting question. If the device manufacturers knew that the spectrum was unlicensed, then the argument could be made that they knowing violated this rule since they didn’t know the amount of power which would be transmitted on neighboring frequencies.

On the other hand, the device manufacturers can argue that their devices were built while no known interferences existed on the neighboring band.

I’m beginning to believe that, in order to reduce the size of their antenna, these devices were increasingly susceptible to the neighboring bands. Because, as AZfederalist suggests, the GPS signals are so weak, that a device with a tiny antenna can’t afford to filter the edges of it’s own spectrum. This leads me to believe that these devices deliberately initiate their filtering outside of GPS spectrum and into neighboring bands.

Now again, I’m not suggesting that FCC allow LS to use their spectrum in any manner which wasn’t licensed to them. I’m simply trying to determine if LS’s claims about GPS systems are truthful or not.

Someone should point out to those Minnesota legislators that maintaining good GPS coverage is a public safety issue. New cell phones have a GPS receiver so that the origin of 911 calls can be logged even if the person dialing the call isn’t able to speak.

They almost certainly are — thanks to the waiver LightSquared got from the FCC to proceed with its plans, based on using a part of the spectrum it already owns and which is most emphatically not authorized for cell phone service. Other cell phone companies had to buy cell-phone service spectrum at auction from the FCC and paid billions of dollars to do so.

Ed, after further study of this issue, I’m not so sure you’re right about this.

I could be wrong, but it seems as if LightSquared licensed it’s spectrum specifically for terrestrial cell phone use in 2004 and that the application process was initiated in 2001.

So, it seems as if you might be mischaracterizing this by claiming that Lightsquared’s spectrum is not authorized for cell phone service. It seems as if this authorization was granted by FCC in 2004.

The waiver it’s seeking seems as if it’s merely based on power adjustments.

Again, I’m not claiming that any of this means that FCC is obligated to allow LightSquared to utilize the bandwidth in a manner which they haven’t already licensed. However, it seems as if GPS interference will occur even if LightSquared decides to operate their system within full compliance of their license.

I’ve read more thoroughly thorough TITLE 47, CHAPTER I, SUBCHAPTER A, PART 15 of the Code of Federal Regulations – as well as some of the other Parts (for example, “Part 2 – FREQUENCY ALLOCATIONS AND RADIO TREATY MATTERS; GENERAL RULES AND REGULATIONS”).

The FCC sticker that Ed mentions seems to be the manufacture’s claim that the product complies with requirements of Part 15. This is because a mere Declaration of Conformity seems to be acceptable for a GPS type of receiver according to §15.101.

According to § 15.19, since a GPS devices is neither a “Receiver[s] associated with the operation of a licensed radio service” nor a “stand-alone cable input selector switch” the Declaration of Conformity, according to § 15.19(3), states that device…

…complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.

First, an overwhelming number of specific requirements of Part 15 seem to deal with making sure that the device doesn’t cause interference with other electronic devices. This is because a GPS system is considered an “UNINTENTIONAL RADIATOR” which means that the electronics within the device emit (radiate) some Electromagnetic Energy at a variety of frequencies which can interfere with other devices.

Second, the only requirements Part 15 seems to specify with respect to avoiding interference are very general.

§15.17 states:

§ 15.17 Susceptibility to interference.

(a) Parties responsible for equipment compliance are advised to consider the proximity and the high power of non-Government licensed radio stations, such as broadcast, amateur, land mobile, and non-geostationary mobile satellite feeder link earth stations, and of U.S. Government radio stations, which could include high-powered radar systems, when choosing operating frequencies during the design of their equipment so as to reduce the susceptibility for receiving harmful interference. Information on non-Government use of the spectrum can be obtained by consulting the Table of Frequency Allocations in §2.106 of this chapter.

(b) Information on U.S. Government operations can be obtained by contacting: Director, Spectrum Plans and Policy, National Telecommunications and Information Administration, Department of Commerce, Room 4096, Washington, DC 20230.

Now, to me, this implies that a before a manufacture puts a Declaration of Conformity sticker on one of their devices rolling off the assembly line, they should comply with this section and obtain information on non-Government use of spectrum which is listed in §2.106.

Now, §2.106 is a huge list of frequency allocation tables in pdf format. It’s cumbersome to navigate, but the table for the frequency range of 941-1525 MHz (it’s two pages which is two consecutive pdfs) seems to indicate that 1452-1492 MHz range (the frequency which LightSquared seems to have licensed in 2004) is allocated to FIXED, MOBILE (except for aeronautical mobile), BROADCASTING, and BROADCASTING-SATELLITE. Now, the fact that satellite broadcasting is listed separately for this band as well as other bands on other tables leads me to believe that it should have been known that 1452-1492 MHz wasn’t limited to satellite transmission.

Since FCC seems to have granted Lightsquared the license for these frequencies for use in non-satellite fixed, mobile, and broadcast transmission systems in 2004, then it’s quite possible that this allocation table has been available to GPS manufactures since 2004.

So, it seems to me that every GPS manufacturer that slapped a Declaration of Conformity sticker on every device since 2004 might have been violating TITLE 47, CHAPTER I, SUBCHAPTER A, PART 15 of the Code of Federal Regulations.

It seems possible to me that the GPS manufacturers were negligent by declaring that their systems would “accept any interference received” knowing that neighboring frequencies were licensed to non-satellite broadcasters, etc.

I might be wrong about all of this, and I’m certainly open to debate so feel free to jump in if I’m off base here.

Now again, I’m not suggesting that FCC allow LS to use their spectrum in any manner which wasn’t licensed to them. I’m simply trying to determine if LS’s claims about GPS systems are truthful or not. In fact, I even understand those that claim that LightSquared shouldn’t be allowed to use the spectrum that they licensed in the manner in which it was licensed because of the GPS interference. However, I think it’s possible that this story might need to modified.

So LightSquared claims that GPS receivers are too broadband and therefore LS signals will compromise them. LS claims that it can be fixed with a “better” GPS design. I don’t doubt that, but the real question is should LS get a waiver for the spectrum it purchased and therefore instantly deem hundreds of millions of GPS units obsolete. Which likely includes GPS’s which are used in aircraft.